Royal Plant Workers Union V

ROYAL PLANT WORKERS UNION,
Petitioner,
vs.
COCA-COLA BOTTLERS PHILIPPINES, INC.-CEBU PLANT
FACTS:
Petitioner Coca-Cola Bottlers Philippines, Inc. (CCBPI) is a domestic corporation engaged in the
manufacture, sale and distribution of softdrink products. IIn the case of the plant in Cebu City, there
are 20 bottling operators who work for its Bottling Line 1 while there are 12-14 bottling operators who
man its Bottling Line 2. All of them are male and they are members of herein respondent Royal Plant
Workers Union (ROPWU).
In 1974, the bottling operators of then Bottling Line 2 were provided with chairs upon their request. In
1988, the bottling operators of then Bottling Line 1 followed suit and asked to be provided also with
chairs. Their request was likewise granted. the chairs provided for the operators were removed
pursuant to a national directive of petitioner. This directive is in line with the "I Operate, I Maintain, I
Clean" program of petitioner for bottling operators, wherein every bottling operator is given the
responsibility to keep the machinery and equipment assigned to him clean and safe. The program
reinforces the task of bottling operators to constantly move about in the performance of their duties
and responsibilities.
CCBPI rationalized that the removal of the chairs is implemented so that the bottling operators will
avoid sleeping, thus, prevent injuries to their persons. The bottling operators took issue with the
removal of the chairs. Through the representation of herein respondent, they initiated the grievance
machinery of the Collective Bargaining Agreement (CBA)
Petitioner argued that the removal of the chairs is valid as it is a legitimate exercise of management
prerogative, respondent espoused the contrary view. It contended that the bottling operators have
been performing their assigned duties satisfactorily with the presence of the chairs; the removal of
the chairs constitutes a violation of the Occupational Health and Safety Standards, the policy of the
State to assure the right of workers to just and humane conditions of work as stated in Article 3 of
the Labor Code and the Global Workplace Rights Policy.
The Arbitration Committee ruled, among others, that the use of chairs by the operators had been a
company practice for 34 years in Bottling Line 2, from 1974 to 2008, and 20 years in Bottling Line 1,
from 1988 to 2008; that the use of the chairs by the operators constituted a company practice
favorable to the Union; that it ripened into a benefit after it had been enjoyed by it; that any benefit
being enjoyed by the employees could not be reduced, diminished, discontinued, or eliminated by
the employer in accordance with Article 100 of the Labor Code, which prohibited the diminution or
elimination by the employer of the employees’ benefit; and that jurisprudence had not laid down any
rule requiring a specific minimum number of years before a benefit would constitute a voluntary
company practice which could not be unilaterally withdrawn by the employer.
ISSUE:
whether the removal of chairs is a violation of art 100 of LC
RULING:
No Violation of Article 100 of the Labor Code

The operators’ chairs cannot be considered as one of the employee benefits covered in Article
10016 of the Labor Code. In the Court’s view, the term "benefits" mentioned in the non-diminution
rule refers to monetary benefits or privileges given to the employee with monetary equivalents.
Such benefits or privileges form part of the employees’ wage, salary or compensation making them
enforceable obligations.
Let it be stressed that the aforequoted article speaks of non-diminution of supplements and other
employee benefits. Supplements arc privileges given to an employee which constitute as extra
remuneration besides his or her basic ordinary earnings and wages. From this definition, We can
only deduce that the other employee benefits spoken of by Article 100 pertain only to those which
are susceptible of monetary considerations. Indeed, this could only be the most plausible conclusion
because the cases tackling Article 100 involve mainly with monetary considerations or privileges
converted to their monetary equivalents.

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ROYAL PLANT WORKERS UNION,

whether the removal of chairs is a violation of art 100 of LC

No Violation of Article 100 of the Labor Code

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